Tyler Cullis February 6, 2017 Is It a New Day in Iran Sanctions? Some are characterizing OFAC's latest designations of Iran-related persons as evidence of a new aggressive posture by the Trump administration.…
Tyler Cullis December 27, 2016 OFAC Amends ITSR, Permits U.S. Person Training On December 23, 2016, OFAC amended the ITSR – the first substantive amendment to the regulations since the advent of…
Tyler Cullis December 19, 2016 Does ISA Extension Violate the JCPOA? With enactment of the Iran Sanctions Extension Act, Iran has called for a meeting of the Joint Commission to seek…
Tyler Cullis December 15, 2016 OFAC Amends Iran FAQs, Issues General License J-1 Acting consistent with its pledge to update its Iran-related FAQs as new questions arise from interested parties, OFAC issued revisions…
Tyler Cullis December 12, 2016 Boeing Enters into Contract with Iran Air In a landmark deal, Boeing finalized its contract with Iran Air for the sale of 80 civil passenger aircraft --…
Tyler Cullis November 25, 2016 OFAC Licenses Airbus’ Sale of Aircraft to Iran OFAC reportedly issued its final batch of specific licenses to Airbus for the export or re-export of civil passenger aircraft…
Tyler Cullis November 21, 2016 The Real Threat to Iran’s Boeing & Airbus Deals Last week, the U.S. House of Representatives passed a bill that could effectively bar the export of passenger aircraft to…
Tyler Cullis November 14, 2016 Escalated Risk Commercially Engaging Iran Post-Trump Commercial engagement with Iran involves multiple levels of risk. With the election of Donald Trump, the legal risk inherent in…
Tyler Cullis November 6, 2016 Mixed Messages: Is the Obama Administration on the Same Page Regarding JCPOA Implementation? Part II The State Department adds a correction to Secretary Kerry's remarks on the due diligence obligations of financial institutions engaged in…
Tyler Cullis November 2, 2016 Mixed Messages: Is the Obama Administration on the Same Page Regarding JCPOA Implementation? Secretary Kerry recently stated that banks need only conduct "normal due diligence" for Iran-related transactions. If true, that'd be news…